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Further Limits to the Exclusionary Rule

During a routine traffic stop, the Phoenix police arrested Evans after a computer inquiry revealed an outstanding misdemeanor warrant for Evan's arrest. In a subsequent search of his car, the officers discovered a bag of marijuana under the passenger seat and the respondent was charged by the state with possession. The justice court later advised the police that the warrant had been quashed 17 days prior to the arrest. Evans moved to suppress the marijuana seized as the fruit of an unlawful arrest. What result? See Arizona v. Evans, 115 S.Ct. 1185 (1995).

 

Nathan Belzer

Emory Law

Answer
The trial court granted the motion to suppress and the Court of Appeals reversed concluding that the purpose of the exclusionary rule would not be served by excluding evidence obtained because of an error by a court employee not directly associated with the arresting officers or the police department. The Arizona Supreme Court reversed and rejected the distinction between clerical errors committed by court employees and similar mistakes by law enforcement personnel.

The United States Supreme Court granted certiorari to determine whether the exclusionary rule requires the suppression of evidence seized incident to an unlawful arrest that resulted from a clerical error, regardless of whether the error was committed by police or court personnel. The Court found a categorical exception to the exclusionary rule when clerical errors of court employees lead to a violation of the Fourth Amendment by arresting officers acting with objectively reasonable reliance on a police computer record. Arizona v. Evans, 115 S.Ct. 1185 (1995).


 
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